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BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C. 20268-0001
POSTAL RATE AND FEE CHANGES, 2001
Docket No. R2001-1
I
RESPONSE OF UNITED STATES POSTAL SERVICE
WITNESS MILLER TO INTERROGATORIES
OF THE ASSOCIATION OF
POSTAL COMMERCE REDIRECTED FROM WITNESS KINGSLEY
(POSTCOMIUSPS-T39-2
AND 6)
The United States Postal Service hereby provides the responses
witness Miller to the following interrogatories
Commerce
redirected from witness Kingsley:
of the Association
of
of Postal
POSTCOM/USPS-T39-2
and 6,
filed on October 17, 2001.
The interrogatories
are stated verbatim and are followed by the
responses.
Respectfully
submitted,
UNITED STATES .POSTAL SERVICE
Daniel J. Foucheaux, Jr.
Chief Counsel, Ratemaking
Anthony Alve&%o
Attorney
475 L’Enfant Plaza West, SW.
Washington, D.C. 20260-l 137
(202) 268-2997; Fax -6187
October 24,200l
RESPONSE OF UNITED STATES POSTAL SERVICE WITNESS MILLER TO
INTERROGATORIES
OF THE ASSOCIATION FOR POSTAL COMMERCE
REDIRECTED FROM WITNESS KINGSLEY
POSTCOMAJSPS-T39-2
Please list and describe all factors that cause an
automation flat to be less expensive for the Postal Service to handle than a
similar nonautomation flat.
(a) Individually for each factor, indicate whether the resulting savings are
modeled in the flats mail processing cost models contained in USPS
LR-J-61.
(b) For each factor not modeled in USPS LR-J-61, please describe in
detail why it reduces Postal Service costs.
(c) For each factor not modeled in USPS LR-J-61, please provide a copy
of all studies, reports, and analyses that discuss or quantify the
benefits to the Postal Service of the factor.
RESPONSE:
The interrogatory
are “similar.”
does not define how the nonautomation
and automation
It is assumed that the only mail piece characteristics
between the two flats are: (1) presence
(2) the address quality associated
that differ
of a barcode on the automation
with each mail piece.
Therefore,
would be the only ones that would affect the mail processing
flats
flat, and
these factors
costs and result in a
cost difference.
(a) Yes. The Bar Code Reader (BCR) and Optical Character
Reader (OCR)
accept rates found in USPS LR-J-61, page 57, were from engineering
quantified the acceptance
percentages
barcoded mail pieces (73.63%)
respectively.
response to POSTCOMAJSPS-T24-1
adjustment
for pre-barcoded
tests that
(93.87%) and non-
In addition, see please the
for a discussion
of how CRA proportional
factors are applied to the model costs to account for the fact that
some tasks are not actually modeled.
(b) (c) Not applicable.
RESPONSE OF UNITED STATES POSTAL SERVICE WITNESS MILLER TO
INTERROGATORIES
OF THE ASSOCIATION FOR POSTAL COMMERCE
REDIRECTED FROM WITNESS KINGSLEY
POSTCOMIUSPS-T39-6
Please provide any reports, studies, analyses or data
that quantify the incidence of or costs of missorted mail.
RESPONSE:
It is assumed that the term “missorted
routed to the incorrect delivery address.
does not have any information
mail” refers to mail pieces that are initially
To my knowledge,
responsive to this request.
response to POSTCOMAJSPS-T24-1.
the Postal Service
Also, please see the
DECLARATION
I, Michael
answers
W. Miller,
declare
are true and correct,
under penalty
of perjury
to the best of my knowledge,
MICHAEL
Dated:
lb-
2’-t-u/
that the foregoing
information,
W. MILLER
and belief.
CERTIFICATE
OF SERVICE
I hereby certify that I have this day served the foregoing
upon all participants of record in this proceeding in accordance
12 of the Rules of Practice.
Anthony Alvernd
475 L’Enfant Plaza West, SW.
Washington, DC. 20260-l 137
(202) 268-2997; Fax -6187
October 24,200l
document
with section
4,&.-;